Twin Oaks - IRS Correspondence with Twin Oaks

Shared by Twin Oaks Community
Tags: IRS, 501d, Overview, Tax Info Package

Tax Information Package - TO-TXP1 - IRS Correspondence with Twin Oaks
01-01-80
Twin Oaks


Tax Information Package - TO-TXP1

IRS Correspondence with Twin Oaks

11/01 Dingo
Department of the Treasury
Washington, DC 20224
Person to Contact: Mr. Orcino
Telephone Number: (202) 566-3667
Refer Reply to: E:EO:T:R:1-2
Date: Feb 26, 1990

Dear Applicant:

We are considering your application for recognition of exemption under section 501(d) of the Internal Revenue Code of 1954 and find that it is incomplete in certain respects. To complete our consideration we need the following information over the signature of one of your principal officers:

1. Please provide us with a full explanation of why you consider yourself a religious or an apostolic organization within the scope of section 501(d) of the Code.

2. What activities that you are presently engaging in would you classify as religious or apostolic activities? Please fully explain.

3. Provide us with a statement whether your income for taxable years 1976 thru
1978 have been allocated to all members or shareholders. Did your members
include such share as part of gross income in their tax return? Does minor
dependent of members receive separate allocation of your income?

4. Describe the outside work performed by your members. Please explain the
necessity of performing such outside work in the operation of your organization.

5. Please provide us with a statement showing the percentage of time devoted by
your members in activities in furtherance of your religious beliefs and the
percentage of time devoted in the conduct of your business activities.

6. Provide us with a detail of items constituting your Business Inventories and
Support Inventories for 1977 and 1978.

7. Provide us with a detail of the account Member Loans for 1977 and 1978. The
schedule should include the name of debtor, amount granted and purpose of loan.

We will defer action on your application for 21 days to enable you to submit this information. When you reply, please include the above symbols as part of our address on the envelope. If we do not hear from you within that time, we will assume you do not want us to consider the matter further and will close your case.

Sincerely yours,

J.E. Griffith
Chief, Rulings Section 1
Exempt Organizations
Technical Branch

Mays, Valentine, Davenport, & Moore
F&M Center P.O. Box 1122
Richmond, Virginia 23208
Telephone (814) 644-6011

Washington, D.C. Office
Suite 1200
1101 Connecticut Avenue N.W. 20036
File No.

March 28, 1980

Mr. Christopher Pax
Twin Oaks Community, Incorporated
Route 4, Box 169
Louisa, VA 23093

Dear Christopher:

Please find enclosed a copy for your records of the response to the Internal Revenue Service's request for additional information with respect to Twin Oaks' I.R.C. $ 501(d) application which I mailed today to the Internal Revenue Service.

Sincerely,
Wallace M. Starke

61/372
Enclosure

Mays, Valentine, Davenport, & Moore
F&M Center P.O. Box 1122
Richmond, Virginia 23208
Telephone (814) 644-6011
Washington, D.C. Office
Suite 1200
1101 Connecticut Avenue N.W. 20036
File No.

March 28, 1980

Mr. J. E. Griffith
Chief, Ruling Section 1
Exempt Organizations
Technical Branch
National Office
Internal Revenue Service
Washington, D.C. 20224

ATTENTION: Mr. ORcino
Your Reference - E:EO:T:R:1-2

Re: Additional Information for Application for Recognition of Exemption
I.R.C. $ 501(d) - Twin Oaks Community, Incorporated

Dear Sir:

This letter is in response to your letter of February 26, 1980 to Twin Oaks Community, Incorporated requesting certain additional information with regard to its application for recognition of an exemption under I.R.C. $ 501(d) of the Internal Revenue Code of 1954 (hereinafter I.R.C. or the Code). Pursuant to agreement reached with Mr. Orcino in a telephone conversation of Friday, March 14, 1980, the response period was extended until March 28, 1980.

Information Requests 1, 2, and 5
Information requests 1, 2, and 5 all involve the same subject. Request 1 asks for a full explanation of why Twin Oaks Community, Incorporated (hereinafter Twin Oaks or the Community) considers itself a religious organization within the scope of Code $ 501(d). Request 2 asks what activities in which Twin Oaks is presently engaging would it classify as religious or apostolic activities. Request 5 asks for a statement showing the percentage of time devoted by members of Twin Oaks in activities in furtherance of its religious beliefs and the percentage of time devoted in the conduct of its business activities. These information requests will be discussed together.
The original application for exemption dated November 27, 1979 described what Twino Oaks believes is its religious views, and attached as Exhibit F thereto is its "Statement of Religious Beliefs - Theory and Practice". The November 27, 1979 application states as follows:

Briefly stated, the purpose of Twin Oaks is the promotion of general equality
among humanity centering upon a basic spiritual and moral inter-relatedness
among all people by promoting non-violence, harmonious cooperation, spiritual
awareness, equality and other values through their physical social structures and
daily interactions.... (page 2)

The first 12 years (1967 to date) have been spent by Twin Oaks building an
alternative society, where members may practice their different values and from
which the members can advocate further development of the beliefs and practices of Twin Oaks. Attached hereto as Exhibit F is a "Statement of
Religious Beliefs - Theory and Practice". Additionally, the purposes of the
organization are defined in the Articles of Incorporation and the Bylaws. See
Exhibits A, Article II, and B, Article II.

In place of the formal services and liturgies of conventional religions, Twin Oaks
focus has been on creating an environment for the daily practice of its beliefs,
which have firm grounding in both religious and humanistic philosophy. As the
Statement of Religious Beliefs (Exhibit F) indicates, Twin Oaks is somewhat
eclectic, as its values and philosophy are in accord with many of the spiritual
values of both Christian and Eastern religion philosophies.

The members of Twin Oaks come from many walks of life, often from
financially secure jobs, in order to take part in a living experience of
brotherhood and sisterhood. Non-violence, harmonious cooperation, spiritual
awareness and equality among other values take on an immediate, living
meaning through the members' daily interactions. The members communal
living and work structures, their removal from the distractions of madern life,
the modest standard of living enjoyed by them and the regular forums for the
collective discussion and implementation of Twin Oaks' beliefs create an
effective crucible for the realization of Twin Oaks' ideals.

Central to Twin Oaks is the concept that there is a basic spiritual and moral
inter-relatedness among all people, and that therefore personal gain must give
way to a loving concern for others. Thus, Twin Oaks practices a community of
property, sharing all that the members own and do with one another....

* * * * * * * * * *

The members of Twin Oaks at all times strive to be loving and caring in their
interactions with each other and all people. Beyond forbidding physical violence
(which is grounds for expulsion), the members extend their practice to the
radical, Ghandian concept of "Satyagraha": non-violence in how people address
each other, and in people's thinking.

The ultimate aim of Twin Oaks is to create a successful example of a loving,
cooperative society, and to further the development of similar organizations
elsewhere.

Twin Oaks conducts a visitor and tour program for those who are interested in
joining the Community or in including Twin Oaks' ideas and practice in their
lives outside the Community. Twin Oaks has aided the formation of several
other communities with similar values and structures. Additionally, Twin Oaks
conducts conferences, a lecture program and publishes a quarterly newsletter
entitled The Leaves of Twin Oaks for the promotion of harmonious, cooperative
living in accordance with its principles.